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Mr. Jack Henris <br />July 13, 2016 <br />Page 2 <br />m:\min\tc1\_teller\m-1980-244 cc-v\am-11\m-80-244-am-11maincommentr12016-07-13.docx <br />submittal, there may be a discrepancy in permit acreage. There are two areas in Section 24: <br />one parallel to Shelf Road, and the other crosses Hwy 67; that were included in the approved <br />Amendment 10 (AM-10) permit boundary and are now being excluded from AM-11/AM- <br />11.1. These two areas were not included in the AR-02 release request, but appear to be <br />incorporated into the subsequent AR-03 request. The Division may request clarification as <br />on this issue as part of the AR-03 review. <br />6.4 SPECIFIC EXHIBIT REQUIREMENTS – 112d DESIGNATED MINING <br />OPERATIONS <br />6.4.3 EXHIBIT C – Pre-mining & Mining Plan Map(s) of Affected Lands <br />2. General comment on maps. <br />a. Drawings C-1 and C-1a have a discrepancy between the scale bar (roughly 1.6 inches = <br />0.25 miles, or 1” = 825’) and the 1:52,000 (1” = 4,333.33 ‘) shown in the title block. It <br />should be noted that Rule 6.2.1(2)(e) requires the scale be between 1 inch = 50 feet and <br />1 inch = 660 feet. However, this Rule also states maps “shall be prepared at a scale that <br />is appropriate to clearly show all elements that are required to be delineated by the Act”. <br />The maps as submitted appear to meet the latter requirement. As such, a change in scale <br />is not required at this time, but please address the discrepancy. <br />b. Contour intervals are not labeled. The use of similar colors is confusing (i.e., the green <br />for “CC&V Gold Mining Company” is very similar to the green for “City of Cripple <br />Creek”, and the blue for “City of Victor” is essentially the same as the blue for “AM 11 <br />Boundary”). Please label contours, provide contour interval, and increase the color <br />palette to reduce confusion and uncertainty. <br />3. Drawing C-1. <br />a. See Comment #2. <br />b. This exhibit is required to show “all immediately adjoining surface owners of record” <br />[Ref. Rule 6.4.3(a)]. The map does not depict which individual “Private Third Party” <br />owns each parcel. Drawing C-1 in AM-10 placed ID numbers on each parcel to <br />correspond to a table in Exhibit O, Owners of Record. The addition of Teller Co. <br />Assessor account numbers to this map and referencing Exhibit O would suffice in <br />meeting this requirement. Please provide a map showing owners of record. <br />4. Drawing C-1a. <br />a. See Comment #2. <br />b. This exhibit is apparently intended to show the owners of all structures within 200 feet <br />of the new affected area boundary (coincident with the permit boundary). Given the <br />course topographic background and section lines, it is extremely difficult to check that <br />all appropriate structure owners are included. Furthermore, given the proximity to <br />numerous residences, complexity of the boundary, and remoteness of some boundary <br />segments, field checking this would also prove to be overwhelmingly time consuming.